Comments for ERO Number 019…

Comments for ERO Number 019-1303

Rather than comment on the numerous and detailed proposed amendments to Ontario Reg. 244/97, I shall make some more general observations and suggestions.

The MNRF analysis of these proposed amendments states “The anticipated social consequences of the proposal are positive”. How could any objective, informed reader possibly come to this conclusion? The social impacts of pits and quarries on local residents and communities are profound. One would hope that “modernizing” policies within the Aggregate Resources Act would actually help to reduce these social impacts but we seem to have lost ground in this latest round of changes.

A proper assessment of social impacts to gauge the negative effects on the quality of life of local residents and communities ought to be a basic requirement of all aggregate applicants. This assessment should include the impact of the proposed haul route. Additionally, it should utilize “total cost accounting” methodology and incorporate property value protection for affected local property owners.

Perhaps the simplest and most effective means of minimizing adverse social impacts to local residents would be to create minimum setback distances from sensitive receptors for pits and quarries. Currently, there is no minimum setback requirement for new pits and quarries which is astonishing. Living in close proximity to these industrial operations with their associated fugitive air emissions can effectively destroy the quality of life for residents. I would suggest a setback of 400 meters to be reasonable for gravel pit applications and 800 meters would be appropriate for quarry applicants.

New applications to mine below the water table as well as amendments to mine below the water table both have enormous potential for damage to local water resources. Consequently, they should both be subject to the same robust application process. The Ministry has recommended nullifying municipal bylaws relating to depth of extraction. I couldn’t disagree more with this change which presumably is industry driven. These are local water resources that local municipalities have a right to protect.

Does the current application process protect local residents and businesses from adverse effects on groundwater and well water? The loss of a reliable source of potable water for a residential property has a dramatic and permanent effect on resale value. At a minimum, applicants should be expected to post monetary security deposits sufficient to rectify or compensate for any water related problems created. An agreement to truck in water to affected residents in no way remunerates equitably for this issue.

I realize the MNRF has a difficult task in balancing community interests while optimizing the extraction of aggregate deposits. Given the proposed changes to these aggregate policies, it is evident that the interests of the aggregate industry are prevailing.

We are an entrepreneurial family and have always supported policies and governments that encourage ambition and free enterprise. I can assure you however, we would never have voted for these industry driven changes to the Aggregate Resources Act.